Unraveling the Fiscal Year 2024 Hospice Payment Rate Update Proposed Rule
Author: Tom Maxwell
Posted Date: April 18, 2023
On March 31, 2023, the Centers for Medicare & Medicaid Services (CMS) proposed a rule (CMS-1787-P) to update Medicare hospice payments and the aggregate cap amount for fiscal year (FY) 2024. This rule aims to ensure that hospices are compensated fairly while addressing growing concerns about fraud, waste, and abuse in the industry. This blog post will delve into the key aspects of the proposed rule and their potential impacts on hospices, patients, and the overall healthcare system.
Medicare Hospice Payment Policies
The proposed rule examines historical hospice utilization trends and solicits comments on increasing access to higher levels of hospice care. It also seeks feedback on non-hospice spending during a hospice election, ownership transparency, and ways to improve hospice selection for patients and caregivers. Additionally, the rule proposes regulations on text changes related to the provision of telehealth services for Routine Home Care and for the use of telecommunications technology for face-to-face encounters conducted by a hospice physician or nurse practitioner for hospice recertification through December 31, 2024.
FY 2024 Routine Annual Rate Setting Changes
The FY 2024 hospice payment update percentage is proposed at 2.8%, an estimated increase of $720 million in payments from FY 2023. Hospices that fail to meet quality reporting requirements will receive a 4-percentage point reduction to the annual hospice payment update percentage increase, resulting in a -1.2% update. The proposed hospice cap amount for the fiscal year is $33,396.55, a 2.8% increase from the FY 2023 cap amount ($32,486.92).
Hospice Quality Reporting Program (HQRP)
The proposed rule aims to codify the HQRP data completion threshold policy at §418.312 and provides updates on initiatives related to the development of the Hospice Outcomes & Patient Evaluation (HOPE) tool, future quality measures, and health equity efforts.
Physician Enrollment and Certification
CMS proposes that physicians who order or certify hospice services for Medicare beneficiaries must be enrolled in Medicare or validly opted-out as a prerequisite for payment for the hospice period of care in question. This is part of a larger effort by CMS to address hospice fraud, waste, and abuse.
Updates on the Consolidated Appropriation Act, 2021 (CAA 2021) Hospice Special Focus Program (SFP)
The proposed rule discusses updates on the CAA 2021 hospice SFP, which aims to improve hospice care quality by addressing issues and concerns in the industry.
The Fiscal Year 2024 Hospice Payment Rate Update Proposed Rule (CMS-1787-P) seeks to balance the need for fair compensation and quality improvement in the hospice industry with concerns of fraud, waste, and abuse. By examining historical trends, seeking public feedback, and making necessary adjustments to regulations, CMS aims to create a more transparent and equitable hospice care system for all stakeholders. Hospice agencies need to take the proposed rule seriously and begin evaluating the needs of their referring providers. It is important to note that the cap increase is minimal and does not keep up with cost-of-living increases.
Maxwell Healthcare Associates is here to assist you in impact mitigation strategies and analysis as we help you navigate the challenges and opportunities presented by these changes. It is crucial for hospice providers, beneficiaries, and patient advocates to engage with the rule-making process and share their insights to help shape the future of hospice care in the United States. Please contact us at [email protected] for more information on our solutions.